The tax treatment of (underpriced) non-family business succession with special consideration of Ticino practice
Does an underpriced transfer of shares to an employee always lead to income tax consequences? With this article, the authors want to stimulate discussion on a very relevant aspect of non-family business succession: the distinction between (income taxable) employee shareholdings and (possibly non-income taxable) succession arrangements. The authors take a look at the practice and case law in the canton of Ticino and other cantons as well as the possible effects of recent inheritance law reforms.
Tax aspects of family business succession
In the coming years, many small and medium-sized companies will face the challenge of arranging their succession. A transfer against payment or free of charge may be considered in order to remain in family ownership. The planning and implementation of succession is an important topic for entrepreneurs with links to numerous areas of law. This article is dedicated to the tax challenges and solution strategies in family business succession in order to support companies in strategically well thought-out and tax-optimized planning.
Far more than cryptocurrencies ...
The editorial for the focus issue "Blockchain, Crypto and NFTs". In recent years, blockchain technology has caused a stir around the world. In this context, tax law has dealt with blockchain technology primarily in connection with cryptocurrencies. However, the scope of blockchain technology goes far beyond cryptocurrencies.
Taxation of NFTs in the luxury industry - a case study
Non-fungible tokens ("NFTs" for short), i.e. unique cryptographic tokens representing physical or digital value, are currently on everyone's lips - at least since the NFT "Everydays: the First 5000 Days" was auctioned by Christie's in 2021 for USD 69.3 million. Using the NFTs of the watch brand DuBois et fils, which were issued for the first time in 2021, it will be shown how companies in the luxury sector can use NFTs both to market products and to build a close customer relationship, and which tax issues have to be taken into account.
Compensation paid by Swiss companies to foreign directors
This video provides information on the possible tax and social security implications of a board of directors resident in an EU country in the case of a Swiss company limited by shares if the board of directors is also self-employed in its country of residence.
Acceptance of tax submission 17 in the canton of Zurich
After the "Federal Law on Tax Reform and OASI Financing" (STAF) was approved at federal level by the people and the cantons with around 66%, the cantonal bill was also accepted with a yes vote of around 56%.
FTA publishes working paper on cryptocurrencies and ICOs/ITOs
The emergence and spread of crypto-currencies have raised various questions about the tax treatment of these book-entry securities. The Swiss Federal Tax Administration (FTA) has published a working paper outlining the practice developed to date (status end of May 2019).
Bundesrat approves key points of a reform of the withholding tax
On 26 June 2019, the Federal Council decided to resume the suspended reform of the withholding tax. To this end, it approved the objectives and the key parameters.
STAF enters into force on 1 January 2020
According to a press release dated 14 June 2019, the Federal Law on Tax Reform and OASI Financing (STAF) will come fully into force on 1 January 2020.
STAF - Abolition of the federal practices for principal companies and Swiss Finance Branches
As part of the implementation of the STAF, the Federal Tax Administration (FTA) will no longer apply the federal practices for principal companies and Swiss Finance Branches from 1 January 2020.
Adoption of the tax reform and AHV financing (STAF) (referendum of 19 May 2019)
After the Corporate Tax Reform III (USR III) was rejected in February 2017, Swiss voters voted on the tax reform and AHV financing (STAF). The proposal was accepted by the people and cantons with around 66% (cf. preliminary official final results).
Clarification of legal information and preliminary tax assessments (tax rulings)
On 29 April 2019, the Federal Tax Administration (FTA) published details of the code of conduct for the provision of legal information and rulings in the areas of value added tax and corporate tax for radio and TV as well as tax rulings for direct federal tax, withholding tax and stamp duties.
FDK publishes survey results on the implementation status of STAF in the cantons
The Conference of Cantonal Finance Directors (FDK) published the results of a survey on the updated implementation status of the Federal Law on Tax Reform and OASI Financing (SV17 / STAF) in a communication dated 10 May 2019.
Differentiation between salary and dividend for employee shareholders
Workshop by Natalie Dini and Barbara Stötzer at the ISIS) seminar on 13/14 September 2021 entitled "Employee compensation in tax and social security law".
Partial retirement - tax and social security aspects
Workshop by Sirgit Meier and Peter Lang at the ISIS) seminar on 13/14 September 2021 entitled "Employee compensation in tax and social security law".
